Treasury Department, Internal Revenue Service
This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States.
Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 10042] RIN 1545-BG08 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regulations. SUMMARY: This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States. DATES: Effective date: These regulations are effective on December 15, 2025. Applicability dates: For dates of applicability, see §§ 1.892-3(c), 1.892-4(d), and 1.892-5(e). FOR FURTHER INFORMATION CONTACT: Jack Zhou at (202) 317-6938 (not a toll-free number). SUPPLEMENTARY INFORMATION: Authority This document contains amendments to the Income Tax Regulations ( 26 CFR part 1 ) under section 892 of the Internal Revenue Code (Code). These regulations are issued under the express delegations of authority under sections 892(c) and 7805(a) of the Code. Background On June 27, 1988, the Department of the Treasury (Treasury Department) and the IRS published in the Federal Register a notice of proposed rulemaking ( 53 FR 24100 ) (1988 proposed regulations) with a cross-reference to temporary regulations under section 892 (TD 8211, 53 FR 24060 ) (1988…
Citation: 90 FR 57901
